A Step Ahead

CCPA Notice  

Information for California Residents

Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), we are providing the following details regarding the categories of Personal Information that we collect, use, and disclose about California residents. Under the CCPA, “Personal Information” is information that identifies, relates to, or could reasonably be linked with a particular California resident or household.

Sources
We collect Personal Information from: Our interactions with you, such as when you use our App contact us online or on the phone, sign up for a newsletter, register an account, purchase a product or service, or attend one of our events; and

Our affiliates, third-party providers of software applications made available on the App and publicly available online sources.

Categories
In the past 12 months, the following categories of Personal Information as listed in the CCPA may have been collected by us: In the past 12 months, the following categories of Personal Information as listed in the CCPA may have been collected by us:

  • Category A. Identifiers, such as name, contact information, IP address and other online identifiers;
  • Category B. Personal information, as defined in the California customer records law, such as name, contact information, payment card number, financial information, employment information, insurance information, and government-issued ID numbers;
  • Category C. Characteristics of protected classifications under California or federal law, such as marital status;
  • Category D. Commercial information, such as transaction information and purchase history;
  • Category F. Internet or network activity information, such as browsing history and
    interactions with our App;
  • Category H. Geolocation data, such as device location;
  • Category G. Professional or employment-related information; and
  • Category K. Inferences drawn from any of the Personal Information listed above to create a profile about, for example, an individual’s preferences and characteristics.

How We Use Personal Information

We use these categories of Personal Information to:

  • Meet our obligations to you with respect to our services and other products;
  • Develop, improve, update, and maintain our products and services;
  • Provide services to our employees and agents;
  • Personalize, advertise, and market our products and services;
  • Conduct research, analytics, and data analysis; and
  • Perform general business transactions, record-keeping, and our day-to-day operations.

Disclosure

In the past 12 months, we have disclosed the following categories of Personal Information as listed in the CCPA to third parties:

  • Category A. Identifiers, such as name, contact information, IP address and other online identifiers;
  • Category B. Personal information, as defined in the California customer records law, such as name, contact information, payment card number, financial information, employment information,
  • Category C. Characteristics of protected classifications under California or federal law, such as marital status;
  • Category D. Commercial information, such as transaction information and purchase history;
  • Category F. Internet or network activity information, such as browsing history and interactions with our App;
  • Category G. Geolocation data, such as device location;
  • Category I. Professional or employment-related information; and
  • Category K. Inferences drawn from any of the Personal Information listed above to create a profile about, for example, an individual’s preferences and characteristics.

We have not sold Personal Information, as “sale” is defined in the CCPA.

Rights as a California Resident

As a California resident, you may request that we provide to you the following information covering the 12 months preceding your request

  • The categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information;
  • The specific pieces of Personal Information we collected about you;
  • The business or commercial purpose for collecting (if applicable) Personal Information about you; and
  • The categories of Personal Information about you that we otherwise shared or disclosed, and the categories of third parties with whom we shared or to whom we disclosed such Personal Information (if applicable).
  • Delete Personal Information we collected from you.

To make a request for the disclosures or deletion described above, please contact us at
[email protected].

As provided under the CCPA, you have:

  • the right to know (request disclosure of) personal information collected by us about you, from whom it was collected, why it was collected, and, if sold, to whom;
  • the right to delete personal information collected from you;
  • the right to opt-out of the sale of personal information (if applicable);
  • the right to non-discriminatory treatment for exercising any rights; and
  • the right to initiate a private cause of action for data breaches. be free from unlawful or discriminatory treatment for utilizing your rights.

In the event, that we engage in services that are considered “financial incentives” as defined under the CCPA, we will give notice of the material terms and receive consent from the applicable individuals before they are included in any such incentive.

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